Former UWM attorney sues for wrongful termination over title letter signing policy

A former corporate attorney is accusing Michigan-based United Wholesale Mortgage (UWM) of retaliation and wrongful termination after he refused to sign attorney opinion letters (AOLs) in states where he was not licensed. The plaintiff claims the requirement stemmed from a policy change implemented in November.

A spokesperson for UWM said in a statement to HousingWire that its attorney opinion letter program, an alternative to traditional title insurance, was thoroughly researched and approved by legal counsel.

“We remain extremely confident in it,” the spokesperson added. “The program was specifically designed to help borrowers across the country save thousands of dollars on title costs related to their mortgage loan closings, which is being done successfully.”

Brad Rosa worked at UWM from February 2024 to December 2025 as in-house counsel in the company’s title review and closing (TRAC) department, which employed nearly 40 attorneys. In his role, Rosa reviewed public land records and issued AOLs for conventional refinance loans under UWM’s TRAC program.

The lawsuit was filed Tuesday in the Superior Court of the State of California for Orange County. Eric B. Kingsley, the plaintiff’s attorney and a partner at Kingsley Szamet Employment Lawyers, also shared comments with HousingWire.

“The benefit to the company (UWM) would be the ability to lower its labor costs,” Kingsley wrote in an email. “By using their own out of state lawyers the company would not need to retain lawyers in the state in question. This is just a corporation cutting corners and ignoring ethical and legal restrictions to enhance profits.”

Lawsuit details

Rosa alleges that this past fall, the TRAC AOL program was replaced by a TRAC+ Title Standing Letter (TSL) program. During this transition, “ghostwriting” — defined in the complaint as preparing title opinions that were then signed by attorneys licensed in the relevant state — was a common practice at the company.

Under the revised program, AOLs were rebranded as TSLs, but “the substance and purpose of both remained the same,” according to the lawsuit. Rosa’s responsibilities also remained unchanged. He issued legal assessments of title status, identifying defects or “clouds,” and evaluating whether a new mortgage would obtain first-lien priority.

But the lawsuit claims attorneys were informed they would eventually be required to sign TSLs for properties located in states where they were not licensed. Concerns with the move were addressed in a 12-page document sent to management, as well as during a meeting held in October involving all TRAC attorneys and managers, per the complaint.

Rosa said his own research showed that some states address the issue through statutes, while others rely on ethics opinions or case law.

In Texas — a state where he allegedly ghostwrote several letters — Rosa said an exception existed only if legal services were provided solely to the company or its affiliates. But TSLs were shared with mortgage brokers to clear titles, potentially falling outside that exception. Also, Rosa claims he and others were not registered as in-house counsel as the work involved state-specific title opinions, not Michigan or federal matters.  

According to the complaint, UWM formally changed its policy in November to require corporate title attorneys to sign TSLs for properties in states where they were not licensed. Attorneys who refused to do so 10 times would have their refusal treated as a resignation.

The new policy recognized that signing such letters without a license was explicitly prohibited in several states, including Alabama, Arizona, California, Florida, Kentucky, Louisiana, New Jersey, Ohio, Pennsylvania and South Dakota.

“The remaining approximately twenty-seven states where the program was active did not expressly prohibit the conduct, but also did not affirmatively authorize it,” the complaint states. 

Rosa alleges the policy change was driven by a backlog of approximately 20 ghostwritten files that lacked signatures by Nov. 28. He claims he offered to sign filings in California and Massachusetts, where he was licensed, and to continue ghostwriting documents for other states, while making clear he did not intend to resign.

But according to the lawsuit, Rosa was terminated on Dec. 3 during a phone call.

The UWM spokesperson said in a statement that the lawsuit “directly reflects the resistance that can come when longstanding industry practices and large insurance companies are challenged. “

“Unfortunately, innovation often brings scrutiny,” the spokesperson added. “UWM will continue to focus on doing what’s right for consumers while defending its position both in this lawsuit and on behalf of its mortgage broker clients.”

Rosa is seeking, among other things, compensatory damages, past and future wages and bonuses, and civil penalties for alleged violations of the California Labor Code. He is also demanding a jury trial.